ML20023C076
| ML20023C076 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/05/1983 |
| From: | Dunning T Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20023C059 | List: |
| References | |
| NUDOCS 8305090625 | |
| Download: ML20023C076 (6) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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TEXAS UTILITIES GENERATING
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Docket Nos. 50-445 COMPANY, et _al.
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50-446
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(Comanche Peak Steam Electric
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Station, Units 1 and 2)
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1 AFFIDAVIT OF THOMAS G. DUNNING I, Thomas G. Dunning, being duly sworn, do depose and state:
Q1.
By whom are you employed, and what is the nature of the work you perform?
A1.
I am employed as a Section Leader by the Instrumentation and j
Control Systems Branch (ICSB), Division of Systens Integration, Office of Nuclear Reactor Regulation, USNRC. A complete description of na prcfessional qualificaticns is attached tc this I
Q2. What is the nature of the responsibilities you have regarding the Comanche Peak Steam Electric Station?
A2.
Section 7 of the Safety Evaluation Report ("SER") for the Instrumentation Control Systems for the Comanche Peak Steam Electric Station, Units 1 and 2 was prepared under my direction.
Q3. Would you describe the scnoe of the subject matter addressed in l
l your affidavit?
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, A3.
I have been asked to address the question of Judge Jordan on page 18 of the transcript of the April 7,1983 Conference call, where it is stated:
And at the same time NUREG-0460 also mentions that the scram system does not meet IEEE-279 criteria. And since this deficiency was pointed out many years ago, we would ask if the Comanche Peak plant has been modified in such a way that it does meet the requirements of IEEE-279?
In particular, I have been asked to address the staff's conclusions on the reactor trip (scram) system for Comanche Peak and its conformance to IEEE-279.
Based on a review of the reactor trip 7
system, the staff concluded that there is reasonable assurance that the Comanche Peak reactor trip system conforms to the applicable regulations. Since IEEE-279 is codified as a regulatory requirement in 10 C.F.R. E 50.55a(h), this conclusion includes conformance to the requirements to IEEE-279.
Q4. With regard to recent Salem event and the lack of diverse reactor trip breakers, do you continua to believe that the staff conclusions are valid?
A4. Yes, IEEE-279 does not address diversity either explicitly or implicitly in its statement of design requirements. General Design Criterion 22 of Appendix A to 10 CFR Part 50 does state, however, that:
I Design techniques, such as functional diversity or diversity in component design and principles of operation shall be used to the extent practical to prevent loss of the protective function.
1 The Comanche Peak reactor trip breakers do include a degree of diver-sity in that in addition to the tripping of the breaker initiated by o
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t either manual or automatic means via the action of the undervoltage trip device, the manual reactor trip also energizes a shunt trip coil which is diverse from the undervoltage trip device.
As a result of the Salem event the benefit of this shunt trip has been clearly demonstrated.
The above statements and opinions are true and correct to the best of my personal knowledge and belief.
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f Thomas G. Dunning '
Subscribed and sworn to before me this #3 day of May, 1983.
Mf5 h b-Notary Public o
My Commission expires:
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TH05AS G'.
DUNNING PROFESSIONAL QUALIFICATIONS INSTRUMENTATION AND CONTROL SYSTEMS BRANCH DIVISION OF SYSTEMS INTEGRATION I have been employed by the Nuclear Regulatory Commission since November 1976.
F' rom June 1979 to the present time, I have been a Section Leader in the Instrumentation and Controls Systems Branch, Division of Systems Integration.
Prior to my present assignment, I served as a Senior Engineering Systems Analyst in the Plant Systems Branch, Division of Operating Reactors.
I have
' participated in the review of instrumentation, control, and electrical systems of numerous nuclear power stations and in the formulation of related standards and Regulatory Guides.
I am duly registered as a Professional Engineer in Control Systems Engineering in the state of Califo'rnia, holding Cert.ificate No. 752 conferred the 13th day of October 1976.
The Instrumentation and Control Systems Branch performs an indepth technical
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review of the design, fabrication, qualification, and operation of nuclear power plant instrumentation and control systems important to safety.
This review includes a comprehensive assessment of the systems for all power reactors, for adherence to appropriate codes and standards implementing the Commission's requirement and encompasses the cohiplete evaluation of the applicant's safety analysis reports, generic topical reports, and other design information.
- Further, the Branch develops the bases for Regulatory. Guides for instrumentation and control systems designs; evaluates experience obtaine'd duri.ng the construction and operation of nuclear power plants and relates this information to future l
evaluations and acceptance criteria; and participates in the development of Regulatory Guides and regulations pertaining to instrumentation and control systems and other systems in the Branch area of responsibility. As a Section
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THOMAS G.. DUN!!ING j
.e Leader, I supervise the work of six staff members in carrying out the responsibilities of the Branch.
I hold a Bachelor of Science degree in Electrical Engineering and a Master of Science degree in Nuclear Engineering which were conferred by the University of Wisconsin; Madison, Wisconsin.
In addition, I have taken post graduate courses in controls systems analysis as well as specialized training in nuclear power plant design and operations, engineering analysis, and fire protection.
My nuclear engineering experience background derives from my current employment at the Nuclear Regulatory Commission and at General Atomic Company, San Diego, California from June 1960 to November 1976.
While assigned to the Division of Operating Reactors I participated in the review and evaluations of instrumentation and control systems design changes for operating reactors.
I_n addition, I was assigned as a group leader in a team review effort of fire hazards analysis reports, including onsite inspec; ions for 13 operating reactors.
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During the 16 years plus at General Atomic, I held various positions in the area of instrumentation and control systems design for High Temperature Gas Cooled Reactors.
I was involved in the preparation of specifications for radiation and process monitoring and control systems for the Peach Bottom Unit I nuclear plant and subsequently spent two years as a startup engineer at this facility.
On the Fort St. Vrain project I was assigned as a Section Leader for the NSSS process control systems and was responsible for the analysis, design and specifications for control and protection systems.
This work included safety analysis and equipment qualification of safety systems in support of operating license requirements.
For one year I was assigned to the Fort St. Vrain site engineering office as lead instrumentation and controls engineer, responsible-for all design changes to instrumentation, control and protection systems.
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subsequently held positions as Project Engineer for nuclear power plant projects.
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